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| What is an Integrated Contingency Plan (“One Plan”)? |
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This one-plan guidance is intended to be used by facilities to prepare emergency response plans for responding to releases of oil and non-radiological hazardous substances. The intent of the NRT is to provide a mechanism for consolidating multiple plans that facilities may have prepared to comply with various regulations into one functional emergency response plan or integrated contingency plan (ICP). A number of statutes and regulations administered by several federal agencies include requirements for emergency response planning. A particular facility may be subject to one or more of the following federal regulations:
- EPA's Oil Pollution Prevention Regulation (SPCC and Facility Response Plan Requirements) - 40 CFR part 112.7(d) and 112.20-.21;
- MMS's Facility Response Plan Regulation - 30 CFR part 254;
- RSPA's Pipeline Response Plan Regulation - 49 CFR part 194;
- USCG's Facility Response Plan Regulation - 33 CFR part 154, Subpart F;
- EPA's Risk Management Programs Regulation - 40 CFR part 68;
- OSHA's Emergency Action Plan Regulation - 29 CFR 1910.38(a);
- OSHA's Process Safety Standard - 29 CFR 1910.119;
- OSHA's HAZWOPER Regulation - 29 CFR 1910.120; and
- EPA's Resource Conservation and Recovery Act Contingency Planning Requirements - 40 CFR part 264, Subpart D, 40 CFR part 265, Subpart D, and 40 CFR 279.52.
Since the issuance of this guidance, water treatment plants serving populations over 3,300 persons have an additional requirement for emergency response plan preparation as part of Water Infrastructure Security regulations.
The primary advantage of the “One Plan” is for facilities covered by multiple regulatory standards to combine the required plans into one document that will be more easily maintained and updated. The EPA and OSHA consider the “One Plan” format as the “desired” format for facilities covered by multiple standards.
We assist facilities in combining their existing plans utilizing the “One Plan” guidance to ensure all the required elements of each plan is incorporated.
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